(UNOFFICIAL COPY TAKEN FROM HER WEBSITE ON 22 MARCH 2010.

THIS IS NOT AN OFFICIAL COURT DOCUMENT)

Dr. Orly Taitz, esq

29839 Santa Margarita Parkway, STE 100
Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
E-Mail: dr_taitz@yahoo.com

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Dr. ORLY TAITZ, ESQ, PRO SE §

Plaintiff, §HONORABLE ROYCE LAMBERTH
§ PRESIDING
v. § Civil Action: 10-151 RCL
§ FIRST AMENDED COMPLAINT
Barack Hussein Obama, § COMMON LAW FRAUD
John Doe 1-100 § NOTICE OF MOTION HEARING
§ MOTION FOR TRO/INJUNCTION
§ MOTION FOR LEAVE OF
§ COURT TO FILE QUO
§ WARRANTO
Defendants. § QUI
TAM
VIOLATION OF PLAINTIFF’S RIGHTS UNDER 5 USC 552
FREEDOM OF INFORMATION ACT
VIOLATION OF PLAINTIFF’S CIVIL RIGHTS UNDER 42 USC 1983, 42
USC 1985
RICO
VIOLATION OF COMMERCE CLAUSE AND OF PLAINTIFF’S RIGHTS TO
GAINFUL EMPLOYMENT AS A DOCTOR OF DENTAL SURGERY UPON
DEFENDANT’S IMMINENT SIGHNING OF THE HEALTH BILL HR 3590
and HR 3962

FIRST AMENDED COMPLAINT

Jurisdiction

The court has jurisdiction under DC statute §§16-3501- 16-3503. Federal

court is proper as diversity between the parties exist and the case revolves

around the Federal Question of eligibility of the President under Quo

Warranto

Parties

Plaintiff – Dr. Orly Taitz, ESQ- hereinafter “Taitz.” The plaintiff is a resident of

California and president of the Defend Our Freedoms foundation. She is a

Doctor of Jurisprudence and a Doctor of Dental Surgery. Through her

foundation she has popularized Constitution and fought violations of

Constitution and civil liberties of UC citizens. As part of her work she has filed

numerous legal actions, representing over 200 US citizens: State

Representatives of different states, candidates on the ballot and high ranked

members of US military. Her clients are seeking release of original vital

records of Barack Hussein Obama, to see if he is eligible for US presidency.

As of now in spite of over 100 legal actions filed all over the Nation by some

13 licensed attorneys and numerous pro se plaintiffs and in spite of 12 citizen

grand jury presentments and indictments, Obama refused to provide any

vital records that would be acceptable in any court of law.

Respondent/Defendant – Barack Hussein Obama, hereinafter “Obama”,

Acting President of the United States and Commander in Chief, who refused

to present in any court of law or to the public any vital records that would

show his eligibility as for US presidency based on Article 2, section 1 of the

Constitution, as one born in the United States to two citizen parents

without allegiance to any other sovereignties. From birth and until now

Mr. Obama had citizenship and allegiance to three other nations: Great

Britain, Kenya and Indonesia.

Standing

Taitz is an attorney and she has submitted to Attorney General Eric Holder

and US Attorney for the District of Columbia Jeffrey Taylor a request to file

Quo Warranto, to ascertain Obama’s legitimacy for presidency . After 9

months of waiting she did not receive any response from either Attorney

General or US attorney for the district of Columbia. She is seeking a ex-

relator status to proceed with Quo Warranto. As Taitz tried to ascertain

Obama’s legitimacy as an attorney, representing her clients, she was

subjected to vicious attacks coming from the media acting as regime official

propaganda, from Obama’s supporters and from some judiciary, acting as

tools to silence her and intimidate her into dropping her legal actions. She

was subjected to numerous death threats, tampering with her car, when a

fumes emissions hose was disconnected and hot combustible fumes were

going back to the engine, as she was driving with her three children in the

car. Several convicted criminals and document forgers were hired by

someone and used in concert to submit perjured affidavits to court and to

forge her signature, in an attempt to influence the judiciary and undermine

her in the eyes of the community and undermine her law license. Her

foundation web site was repeatedly hacked and destroyed. Her pay-pal

account was tampered with. On 01.21.09. her case Lightfoot v Bowen was

erased from the docket of the Supreme Court of the United States only two

days before it was supposed to be heard in conference by all nine justices.

After a year and a half of repeated complaints to law enforcement, she could

not get any assistance or relief. When she brought two legal actions in the

Middle District of Georgia on behalf of the members of the US military, as a

form of intimidation and retaliation, she was sanctioned $20,000. Taitz is

seeking not only verification of Obama’s legitimacy under Quo Warranto, but

financial compensation for damages suffered as well as compensation for the

severe emotional distress suffered as a result of the defendant’s actions.

Taitz has also submitted request for disclosure of pertinent information under

the Freedom Of Information Act from Social Security Administration under 5

USC 552 (b)(6), her request was denied by Dawn S. Wiggins, FOIA officer of

the SSA, Taitz is appealing this above denial.

Taitz is a Republican candidate on the ballot, running for the position of the

Secretary of State of CA. Based on prior legal action, it is clear, that if

elected, Taitz will demand from Obama all proper vital records to prove his

legitimacy for presidency. As Taitz has filed her Declaration of Candidacy, her

whole family, including her 3 children were subjected to vicious intimidation

and harassment campaign.

Here come the plaintiff Dr. Orly Taitz ESQ and alleges, that District of

Columbia jurisdiction allows Quo Warranto ex relator status in the name of

the United States against a person who within the District of Columbia

usurps, intrudes into, or unlawfully holds or exercises, a franchise conferred

by the United States, civil and military”. D.C. Code §§16-35-1-3503. Quo

Warranto is the mechanism of redress of grievances going back to Magna

Carta.

The foundation of inviolability of Constitution as supreme law was codified in

Magna Carta (1215): “ . .we have granted all these concessions, desirous

that they should enjoy them in complete and firm endurance forever, we give

and grant to them the underwritten security,. . . so that if we, or our

justiciar, or our bailiffs or any one of our officers, shall in anything be at fault

towards anyone, or shall have broken any one of the articles of this peace or

of this security, and the offense be notified . . .laying the transgression

before us, petition to have that transgression redressed without delay. . . .

And we shall procure nothing from anyone, directly or indirectly, whereby

any part of these concessions and liberties might be revoked or diminished;

and if any such things has been procured, let it be void and null, and we shall

never use it personally or by another.” Magna Carta 17 John § 61 (1215)

(Avalon)

The supremacy and inviolability of Constitution is shown by ongoing rulings

that laws or actions are “void and null”, “null and void”, “void”, or “null” etc.

e.g., Chief Justice John Marshall affirmed this constitutional supremacy in

Marbury v. Madison, observing:

“Certainly all those who have framed written constitutions contemplate

them as forming the fundamental and paramount law of the nation, and,

consequently, the theory of every such government must be, that an act of

the legislature, repugnant to the constitution, is void.” Marbury v. Madison, 5

US 137, 176 – Supreme Court 1803

However, Magna Carta codified the supremacy and inviolability of

constitution over both the Executive (“We”/the King) and the Judiciary

(“justiciar”/Chief Justice). Thus paraphrasing Marbury at 178:

“So if a [doctrine] be in opposition to the constitution; if both the

[doctrine] and the constitution apply to a particular case, so that the court

must either decide that case conformably to the [doctrine], disregarding the

constitution; or conformably to the constitution, disregarding the [doctrine];

the court must determine which of these conflicting rules governs the case.

This is of the very essence of judicial duty.”

J. Marshall further emphasized the judicial oath:

“Why otherwise does it direct the judges to take an oath to support it?

This oath certainly applies in an especial manner, to their conduct in their

official character. How immoral to impose it on them, if they were to be used

as the instruments, and the knowing instruments, for violating what they

swear to support!” Marbury v. Madison, 5 US 137, 179 – Supreme Court

1803
The Plaintiff is seeking to uphold explicit Article II and Amendment XX

qualification requirements and grant access (“standing”) under Article VI

supremacy and oath. Any citizen has standing to uphold the Right to redress

of grievances under 1st, 9th amendment. Additionally, 16-3502,3503 does not

limit ex relator status to any particular group and does not require any

particular damages, however there is a heightened right to redress of

grievances for an attorney who was subjected to sanctions, intimidation and

harassment, while she tried to represent her clients seeking to specifically

redress such grievance. There is an additional heightened standing for a

Candidate on the ballot, running for the position of the Secretary of State,

where a big part of her campaign is legitimacy of elections, and where she

and her three children and her whole family are being threatened, harassed

and intimidated with death threats, her car is being tampered with, and she

is threatened with loss of her livelihood.

The plaintiffs have filed both with the Attorney General Eric Holder and

the US Attorney Jeffrey A. Taylor and his successor Channing Phillips a

request for Quo Warranto in March and April of 2009 respectively. Hundreds

of concerned citizens have called the Department of justice demanding a

response to Quo Warranto submission. No response was received for ten

months. Letters, e-mails, faxes went unanswered. Employees of the justice

department were slamming phones in the face of the citizens calling and

urging a response, even when those calls came from high ranking officers of

US military. This game of hide and seek by the Attorney General Holder and

US attorneys played with the plaintiffs and their counselor is infantile at best
and treasonous at worst, as National Security is on the line. Recent near

tragedy of NorthWest 253, slaughter of CIA agents and tragedy at Fort Hood

are only a few reminders of how dangerous it is to have a Big Question Mark

with numerous stolen and fraudulent social security numbers sitting in the

position of the President and Commander in Chief.

WHEREFORE, the undersigned counsel respectfully requests this Honorable

Court to grant Leave of Court to file Quo Warranto as ex-relator in the

name of the United States of America against Barack Hussein Obama,

President of the United States.

Writ of Quo Warranto

QUESTIONS PRESENTED

I. What is Respondent Obama’s standard and burden of proof of his

birthplace under Quo Warranto and ethical duties? – Considering Obama’s

first cousin Raela Odinga, Prime Minister of Kenya, sealed alleged records of

Obama’s birth in Mombasa; while the State of Hawaii holds Obama’s

“original” sealed birth records, allows registration of births out of State,

allows registration based on a statement of one relative only without

any corroborating evidence and seals original birth records.

II. Does the State of Hawaii’s withholding Respondent’s Obama’s original

birth records by privacy laws breach the U.S. Const. by obstructing

constitutional rights duties of the People to vote, and State and Federal
election officers to challenge, validate & evaluate qualifications of presidential

candidates based on legally acceptable and not fraudulent records and the

President Elect., per U.S. Const. art. II § 1, art. VI, & amend. XX § 3?

III. Does the restrictive qualification for President of “natural born

citizen” over “citizen” include allegiance to the U.S.A. from birth without any

foreign allegiance, as required of the Commander in Chief in time of war to

preserve the Republic, including birth within the jurisdiction of the U.S.A. to

parents who both had U.S. citizenship at that birth, and having retained that

undivided loyalty?

IV. Does birth to or adoption by a non-citizen father or mother incur

foreign allegiance sufficient to negate being a “natural born citizen” and

disqualify a candidate from becoming President?

V. Having attained one’s majority, do actions showing divided loyalty

with continued allegiance to the foreign nationality of one’s minority evidence

foreign allegiance sufficient to disqualify one from being a “natural born

citizen” with undivided loyalty to the U.S.A., such as campaigning for a

candidate in a foreign election, or traveling on a foreign passport?

VI. Does a presidential candidate or President Elect by default fail to

qualify under U.S. Const., art. II § 2 and amend. XX, § 3, if they neglect

their burden to provide State or Federal election officers prima facie

evidence of each of their identity, age, residence, and natural born

citizenship, sufficient to meet respective State or Federal statutory

standards?

VII. Do candidates for office disqualify themselves if they seek office

under a birth name differing from a name given by adoption, or vice versa,

when they neglect to provide election officers prima facie evidence of legal

changes to their name, or if they neglect to legally change their name?

VIII. Does a President elect fail to qualify through breach of ethical

disclosure duties, and obstruction of election officers’ constitutional duties to

challenge, validate and evaluate qualifications for President, by withholding

or sealing records evidencing identity, age, residency, or allegiance, or by

claiming privacy and opposing in court efforts by Electors, election officers, or

the People to obtain and evaluate such records?

IX. Does misprision by Federal election officers cause a President Elect

to fail to qualify, if they neglect or refuse to challenge, validate, or evaluate

qualifications of Electors or a President Elect, being bound by oath to support

the Constitution and laws, after citizens provided information challenging

those qualifications via petitions for redress of grievance, or by law suits?

X. To uphold its supremacy and inviolability, and to preserve the

Republic, does the U.S. Constitution grant standing to Citizens to bring suit

or quo warranto over negligence, obstruction, misprision, or breach of

constitutional duties, and protect the People’s rights?

Here come the plaintiffs/ ex-relators in the name of the United States of

America praying this Honorable Court issue Quo Warranto writ against

Barack Hussein Obama, President of the United States and Commander in

Chief.

Ex Relators are seeking Quo Warranto under District of Columbia Codes

§§16-3501-16-3503 which provides for the “Writ of Quo Warranto to be

issued in the name of the United States of America against a person who

within the District of Columbia usurps, intrudes into, or unlawfully holds or

exercises, a franchise conferred by the United States or a public office of the

United States, civil or military”. The ex-relators assert that respondent

Obama has indeed usurped the franchise of the President of the United

States and the Commander in Chief of the United States Military forces due

to his ineligibility and non-compliance with the provision of the Article 2,

Section 1, Clause 5 of the Constitution of the United States that provides

that the President of the United States has to be a Natural Born Citizen for

the following reasons:

The legal reference and legal definitions used by the framers of the

Constitution was the legal treatise “The Law of Nations” by Emer De Vattel as

quoted and referenced in the Article 1, Section 8. The Law of Nations defines

“…Natural Born Citizens, are those in the country, of parents who are

citizens. As the society cannot exist and perpetuate itself otherwise than by

the children of the citizens, those children naturally follow the conditions of

their fathers, and succeed to all their rights.” Book 1, Chapter 19, §212. In

his book Dreams From my Father as well as on his web site Fight the

Smears respondent Obama admitted to the fact that his father was never a

US citizen, but rather a British citizen from a British colony of Kenya and

based on British Nationality act respondent Obama was a British citizen at

birth and a Kenyan citizen from age 2 on December 12, 1961 when Kenya

became an independent nation. As such, for the reason of his allegiance to

foreign nations from birth respondent Obama never qualified as a Natural

Born citizen.

In spite of some 100 legal actions filed and 12 Citizen Grand Jury

presentments and indictments Respondent Obama due to his ineligibility

never consented to unseal any prima facie documents and vital records that

would confirm his legitimacy for presidency.

The state of Hawaii statute 338-5 allows one to get a birth certificate

based on a statement of one relative only without any corroborative evidence

from any hospital. Respondent Obama refused to unseal a birthing file (labor

and delivery file) evidencing his birth from the Kapiolani Hospital where he

recently decided, that he was born. Similarly, respondent Obama refused to

consent to unseal his original birth certificate from the Health Department in

the state of Hawaii. The original birth certificate is supposed to provide the

name of the hospital, name of the attending physician and signatures of

individuals in attendance during birth. As such there is no verifiable and

legally acceptable evidence of his birth in the state of Hawaii.

Circa 1995 Respondent Obama has made an admission in his book Dreams

from My Father that he has a copy of the original birth certificate, when

describing a certain article about his father he write “…I discovered this

article, folded away among my birth certificate and old vaccination forms…”

In spite of the fact that respondent Obama has a copy of his original birth

certificate, he released for public consumption only a COLB, an abbreviated

certification of life birth which was issued in 2007 and does not provide any

verifying information, such as name of the hospital and name of the

attending physician and signatures, which infers that he knows that he is not

eligible and actively trying to obfuscate the records in order to usurp US

presidency. An affidavit from one of the most prominent forensic document

experts, Sandra Ramsey Lines, previously submitted to this court, states that

authenticity of COLB and inference of the US birth cannot be ascertained

based on COLB alone without examining the original birth certificate in

Hawaii, that respondent Obama refuses to unseal and present in court and to

the public at large.

As respondents schools records from Indonesia, previously submitted, show

him the citizen of Indonesia under the name of Barry Soetoro, and there is

no evidence of legal name change upon his repatriation from Indonesia,

there is a high likelihood of the scenario whereby the respondent was sworn

in as a president not only illegitimately due to his allegiance to three foreign

nations, but also under a name that was not his legal name at the time of

inauguration and swearing in as the president.

Affidavits from licensed private investigators Neil Sankey and Susan Daniels,

previously submitted to this court, show that according to national databases

respondent Obama has used as many as 39 different social security

numbers, none of which were issued in Hawaii, which in itself is an evidence

of foreign birth. Most egregious is the fact that the respondent has used for

most of his life in Somerville Massachusetts, Chicago, Illinois and currently in

the White House SSN XXX-XX-4425, which was issued in the state of

Connecticut between 1976-1979 and assigned to an individual born in 1890,

who would have been 120 years old, if he would be alive today. Respondent
never resided in the state of Connecticut and he is clearly not 120 years old.

There is such a high probability of criminal acts of identity theft and social

security fraud committed by the respondent that the undersigned requests

this Honorable court to use its inherent powers to order Sua Sponte an

evidentiary hearing on this particular issue for possible criminal prosecution

of identity theft and social security fraud, as the respondent has submitted

himself to the jurisdiction of this Honorable court and can be brought to a

separate evidentiary hearing to ascertain if fraud was perpetrated upon the

court by assertion of false identity, even if the underlying case is not heard

or closed for one reason or another. The undersigned requests to bar the US

attorney’s office from representing the respondent in such hearing based on

US Code 44 Section 22 and due to obvious inherent conflict of interest.

COMMON LAW FRAUD

1.Plaintiff re-alleges everything previously plead, incorporates by reference

and alleges the following:

2.Defendant knows that his social security number starts with digits 042,

which is assigned to the state of CT.

3.Defendant knows that the social security number he is using was issued in

the state of CT to another individual, who was born in 1890.

4.Defendant was served by the plaintiff with pleadings, where above

information was provided to the defendant.

5.Defendant has a copy of his original birth certificate from HI.

6.Defendant has his school enrolment records from Occidental College,

Columbia University and Harvard University.

7.Defendant knew that his vital records do not provide basis for his assertion

of legitimacy for US presidency under Article 2, Section 1 of the US

Constitution.

8.Defendant committed fraud and misrepresentation of material facts by

placing his name on the ballot as a legitimate candidate for

presidency.

9.Defendant committed fraud by taking an oath of president of the United

States.

10. Plaintiff represents some 200 plaintiffs and on behalf of those plaintiffs

sought release of the defendants above mentioned vital records .

11.Plaintiff was subjected to over a year of intimidation, harassment,

retaliation, sanctions, ridicule, death threats due to the fact that she tried to

unseal the above vital records, showing the plaintiff illegitimate for

presidency and committing fraud.

12.Plaintiff has suffered severe mental anguish and distress and financial

damages as a result directly attributable to the Plaintiff’s conduct and

actions.

Qui Tam

COMPLAINT PURSUANT TO FEDERAL FALSE CLAIMS ACT

Due to the fact that neither Attorney General Eric Holder nor US Attorney

for the District of Columbia respondent to the Quo Warranto demand, plaintiff

is seeking a leave of court for ex relator pursuant to the federal False Claims

Act, 31 USC 3729- 3733 as well against the defendant/respondent Barack

Hussein Obama as further attempts to elicit respond from the Attorney

General or US attorney will be futile.

1.The relater re- alleges previously plead, incorporates by reference and

pleads the following:

2. This cause of action arises under the federal False Claims Act

found at 31 USC 3729 through 3733. This particular District Court for the

District of Columbia affords the proper venue for this action in that the

defendant has submitted within the District of Columbia his false and

wrongful claim for the payment of monies by the United States Government

and the Department of the Treasury located also within the District of

Columbia .

3. A right of private party to proceed in Qua Tam was upheld in

Vermont v. United States, 529 US 765 (2000)

4. The United States Government is the party on whose behalf the

relator also brings this action, as well as on his own behalf, as required by

the False Claims Act.

5. Defendant/ respondent did not fulfil the Constitutional

requirement of Natural Born Citizen.

6. Defendant / respondent has received a salary as a President and

Commander in chief in Violation of the False Claims act USC 3729 through

3733.

WHEREFORE, pursuant to the procedures and remedies set forth in

the federal False Claims Act, relator, on his own behalf and on behalf of the

Government of the United States of America demands enforcement of Qui

Tam

MOTION FOR RELEASE

OF INFORMATION UNDER 5USC 552

FREEDOM OF INFORMATION ACT

PLAINTIFF re-alleges all of the above, incorporates by reference and alleges

the following:

1.Plaintiff has requested information from the Social Security administration

seeking explanation, why the defendant is using Social security

numbers of other individuals and numbers that were never assigned

and what action is Social Security administration is taking to prosecute

this conduct.

2.Plaintiff received a response from a SSA FOIA officer, Dawn S. Wiggins,

denying her request due to privacy.

3.Attached affidavit of investigator Sankey shows 39 different social security

numbers connected to Barack Obama or Barry Obama. When one is

using (x) multiple social security numbers, clearly at least (x-1) or (x)

numbers are being used fraudulently, whereby there is no right to

privacy or expectation of privacy in a fraudulent use of the social

security numbers of others or numbers that were never assigned.

4.Plaintiff is damaged and will be more damaged in the near future, if the

applications for the Social Security numbers listed in the above

reports are not disclosed, and explanation is not provided by what

right, by what warrant Defendant is using or have been those Social

 Security numbers.

5.Plaintiff is seeking a Writ of Mandamus from this Honorable Court to obtain

the above information from Michael Astrue, Commissioner of the Social

Security Administration.

VIOLATION OF COMMERCE CLAUSE AND OF PLAINTIFF’S RIGHTS TO

GAINFUL EMPLOYMENT AS A DOCTOR OF DENTAL SURGERY UPON

DEFENDANT’S IMMINENT SIGHNING OF THE HEALTH BILL

1.Plaintiff re-alleges and incorporates by reference everything alleged

previously and alleges the following:

2.Plaintiff is a Doctor of Dental Surgery, licensed by the state of California.

3.Plaintiff owns and operates a dental practice at 29839 Santa Margarita

PKWY, Rancho Santa Margarita CA.

4.Currently US House of Representatives is set approve via reconciliation one

of two versions of the Health Bill (House Bill HR 3962 and “Senate Bill”

to be reconciled in the House as HR 3590 are substantially Different).

Defendant has repeatedly stated that if such bill is passed and

reconciled as early as next week, he will immediately sign it into law in

spite of general public outcry against such bill. This signing of the bill

is imminent as Defendant, his administration and Democratic party

leadership have engaged forceful arm twisting and de-facto bribery of

US Senators in order to push passing of such bill, whereby Senator

Mary Landrieu of Louisiana got a 100 million dollar de-facto bribe

(Better known as a new “Louisiana Purchase”), senator Christopher

Dodd of Connecticut got 300 million de-facto bribe and Senator Ben
 Nelson of Nebraska got an infinity amount of dollars de facto bribe

to sign the Senate version of such bill.

5.Defendant has never provided any vital records to show that he is

legitimate to hold position of the President and sign such bill into law.

6.Plaintiff will be directly affected by such bill, if signed into law as early as

next week.

7.Health bill, as being prepared and reconciled, will create an enormous

machine of governmental burocracy which will intrude into Plaintiff’s

practice, will affect her doctor-patient relations, will undermine her

Hippocratic oath, will force her to ration medical care and de-facto

deny medical care to elderly, whom some committees of burocrats will

deem to be too old to receive such care, meaning too old to live.

8.Such bill will subject her to threat of multiple Medical-Dental malpractice

legal actions as standard of care will clearly go down.

9.Such bill will constitute unreasonable infringement upon her gainful

employment in Dental Surgery as overburdening of interstate

commerce in clear violation of commerce clause.

10.Wherefore the Plaintiff seeks a writ of Mandamus, seeking release of the

Defendant’s vital records, such as his original birth certificate, his college and

university enrollment records, social security application and passport

application records to verify his legitimacy to sign Health Bill HR 3590 or HR

3962 or any other bill under the Natural Citizen requirement of the Article 2,

Section 1and seeking a declaratory relief deeming Health Bill HR 3590 and

HR 3962 null and void as violating Commerce clause and not signed by a
legitimate President of the United States.

Violation of Plaintiff’s Civil rights under 42 USC 1983, 42 USC 1985.

Plaintiff re-alleges and incorporates by reference all of the above and alleges

following

1.Plaintiff is one of two Republican candidates on the ballot in the state of

CA. Democrat candidate on the ballot is an incumbent Debra Bowen.

2.Plaintiff’s children were intimidated and harassed with e-mails stating that

their mother will be thrown in prison and committed to mental

institution. They received paintings of their mother, depicted nude,

giving birth and holding a bloody placenta, titled “Birther Orly Taitz”.

This was clearly done to intimidate and harass not only Taitz’s children

but also Taitz, herself, and pressure her into dropping out of the race,

as well as to cause her and her whole family severe mental anguish.

Plaintiff has filed a criminal complaint with Orange County Registrar of

Voters, Mr. Neal Kelley. (Exhibit –Criminal complaint, filed with the

Registrar of Voters)

3.Mr.Kelley has called in response to the complaint and stated that it will be

forwarded to the Secretary of State Debra Bowen, who has an

investigative unit.

4.In and around the time of the incidents of harassment Plaintiff has received

a copy of a campaign mailer sent by the campaign of Debra Bowen,

Secretary of State, who is a top official, would be investigating the

Plaintiff’s complaint.

5.Bowen’s mailer states ”Please contribute today to help Debra stand against
 right-wing ideoloques like Orly Taitz”…”…Her (Taitz) primary reason for

running is to challenge President Obama’s citizenship and invalidate

the 2008 election. In Fact, Taitz has sued Debra twice to try to

invalidate Obama’s victory. We can’t let fringe conspiracy theories use

this office to get a foot in the door and undermine our democracy”..’

“please donate $25 or more today so Debra can defeat Orly Taitz…”

Exhibit Flier from Debra Bowen.

6.Clearly Plaintiff, Dr. Orly Taitz, cannot expect any impartiality or any

assistance, when the governmental official, Secretary of State, who is

supposed to investigate intimidation, harassment, hate crimes against

Taitz and her children and her whole family, as related to elections, is

the one who is spreading absolutely despicable defamatory, slanderous

statements about Taitz, is the one who is masterminding the hysteria

against Taitz, which in turn leads to hate crimes against Taitz and her

family.

7.7. Such behavior clearly shows violation of voting rights and Plaintiff’s

rights to be an un-intimidated candidate on the ballot. Secretary of

State Bowen acted for the benefit and as a de-facto agent of the

Defendant, whereby she admits in her own flier, that there is a

threat of invalidation of Obama’s election, if Taitz is elected.

This represents a violation of Plaintiff’s rights under 42 USC

1983 and 42 USC 1985.

8.Defendant’s unwillingness to unseal any and all of his vital records only

fuels such attacks on Taitz and behavior of officials directed towards

 aiding and abetting of consealment of such records obstruction of

records and violation of Taitz civil rights under the color of authority.

9.Wherefore Plaintiff seeks an adjudication in her favor and determination

that her civil rights under 42 USC 1983 and 42 USC 1985 were

violated and she seeks damages incurred as a result of such violation.

RICO

1.Plaintiff re-alleges and incorporates by reference all of the above and

alleges the following:

2.Fraud, as described and alleged previously constitutes a predicate act

under RICO

3.Violation of 42 USC 1983 and 1985 constitutes a predicate act under RICO.

4.On January 21st of 2009 my case Lightfoot v Bowen was erased from the

docket of the Supreme Court. This suggests aiding and abeting in

commission of fraud and a corrupt organization with a common

scheme to defraud the country. As further investigation is necessary,

the plaintiff cannot state prior to discovery, who was engaged in

erasing of records.

5.On October 1st, 2009 Sidharth Velamoor, attorney for Perkins Coie,

Obama’s defense firm, where Robert Bauer, White House Chief

Counsel, is a partner was hired as a clerk for Judge David O. Carter.

Shortly thereafter Judge Carter has changed his opinion and decided

that he no longer has jurisdiction to hear Barnett et al V Obama et al,

which dealt with Obama’s illegitimacy to presidency. Those actions

 suggest improper influence on the Federal judge in an effort to affect

the outcome of the litigation, where defendant was likely to be found

illegitimate to presidency. Those facts suggest violation of the civil

rights of Taitz, an attorney on the case, and her clients under 42 USC

1983, which constitutes a predicate act under RICO.

6. Licensed investigators Susan Daniels and Neil Sankey have provided

affidavits, showing Obama using multiple Social Securty numbers,

none of which were issued in Hawaii, which indicates violation of 42

USC 408 (a)(7)(b), a predicate act under RICO.(Exhibits Affidavits of

Susan Daniels and Neil Sankey)

7. John Sampson, Retired Senior Deportation Officer of the United States

Department of Homeland Security, Immigration and Customs

Enforcement (DHS ICE), recipient of advanced training from federal

Law Enforcement Center, currently a private investigator has provided

an affidavit, showing that the Defendant has used a social security

number, issued in the state of Connecticut, while he resided in HI.

Both investigator Sampson and Sankey were subjected to retaliation

and their privileges to use National databases were rescinded in

retaliation, upon them providing Taitz with the information showing

the defendant fraudulently using Social Security numbers of others.

This is indicative of fraud, obstruction of Justice, Social Security Fraud

and Identity theft- all predicate acts under RICO.

8.Plaintiff is seeking to plead RICO more fully upon conducting and

completion of discovery, which is currently impeded due to plaintiff’s

 refusal to unseal any and all information and due to the Fact that

governmental officials, currently not named, are aiding and abetting in

such obfuscation of records.

Wherefore:

1.Plaintiff ex-relator in the name of the United States of America is

requesting this Honorable Court to issue a writ of Quo Warranto

against a respondent Barack Hussein Obama and order an evidentiary

hearing whether fraud upon the court was committed and whether

criminal charges should be brought against the respondent for fraud,

identity theft and social security fraud.

2.Pursuant to the procedures and remedies set forth in the federal False

Claims Act, Plaintiff-ex relator, on his own behalf and on behalf of the

Government of the United States of America demands enforcement of Qui

Tam

3.Wherefore the Plaintiff seeks a writ of Mandamus, seeking release of the

Defendant’s vital records, such as his original birth certificate, his college and

university enrollment records, social security application and passport

application records to verify his legitimacy to sign Health Bill HR 3590 or HR

3962 or any other bill under the Natural Citizen requirement of the Article 2,

Section 1and seeking a declaratory relief deeming Health Bill HR 3590 and

HR 3962 null and void as violating Commerce clause and not signed by a

legitimate President of the United States.

4. Plaintiff seeks declaratory relief and adjudication I that common law fraud
was committed by the Defendant in his declaration of Candidacy to

presidency, and based on this fraud Plaintiff suffered damages. Plaintiff is

seeking compensation for the damages suffered as well as severe emotional

distress suffered due to the fraud committed by the Defendant.

5. Plaintiff is seeking Declaratory relief in that the Defendant has no right to

privacy or expectation of privacy in his use of multiple Social Security

numbers, numbers issued in other states, where he never resided, as well as

numbers never assigned. Plaintiff seeks the writ of Mandamus in disclosure of

the application for the social security number 042-68-4425.

6. Wherefore Plaintiff seeks an adjudication in her favor and determination

that her civil rights under 42 USC 1983 and 42 USC 1985 were violated and

she seeks damages incurred as a result of such violation.

7. Plaintiff is seeking damages under RICO, to be fully plead and ascertained

upon completion of discovery.

/s/ DR ORLY TAITZ ESQ

By:__________________________________

Dr. Orly Taitz, Esq. (California Bar

223433)

Attorney for the Plaintiffs

29839 Santa Margarita Parkway ste 100

Rancho Santa Margarita CA 92688

Tel.: 949-683-5411; Fax: 949-766-7603

E-Mail: dr_taitz@yahoo.com

PROOF OF SERVICE

I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE

PLEADINGS WAS SERVED on

Channing Phillips, US Attorney for the District of Columbia

501 3 rd str. NW

Washington DC

/s/Orly Taitz

Dr. Orly Taitz Esq

29839 Santa Margarita PKWY

Rancho Santa Margarita CA 92688

1.Exhibit 1 Affidavit from Investigator John Sampson

2.Exhibit 2 Affidavit from licensed Investigator Susan Daniels

3.Exhibit 3 Affidavit from the investigator Neil Sankey

4.Exhibit 4 Campaign flier of CA SOS Debra Bowen

5.Criminal complaint filed with the office of Neal Kelley, the Registrar of

Voters of Orange County

FOIA Appeal